EPA has identified leaks from equipment and components as the single greatest source of volatile organic compounds (VOCs) and hazardous air pollutants (HAPs) emitted from petrochemical and other chemical manufacturing and processing facilities. In response, the agency has included stringent leak detection and repair (LDAR) requirements as part of more than 25 New Source Performance Standards (NSPS) introduced since the early 1990’s.
LDAR program requirements affect a wide range of facilities and industrial activities, and with the recent additions of NSPS Quad O and Quad Oa aimed at reducing emissions from the upstream and midstream petroleum segments, that list has grown to include all onshore oil and natural gas production, transmission and storage facilities constructed after August 23, 2011.
Yet, despite the widespread applicability of LDAR requirements, the agency still reports a high rate of noncompliance. EPA analyzed past LDAR enforcement actions and found that violations are frequently due to a relative handful of root causes. These include poorly developed Written LDAR Program plans, insufficient training for LDAR technicians, and inadequate recordkeeping practices that result in a lack of traceability and accountability for LDAR program activities.
Written LDAR Program Plan
While the development and submission of a written plan is mandatory under LDAR program requirements, its value is much greater than mere compliance. The Written LDAR Program plan serves as the primary source for policies and procedures used to identify, monitor and ultimately prevent fugitive emissions. Your written plan is a critical document that should be carefully developed, revised as necessary to reflect changes at your facility, and made easily accessible so that responsible personnel can refer to it as needed.
A well-developed Written LDAR Program plan should include the following elements:
A list of all equipment in service that has the potential to leak VOCs and other HAPs at your facility
Procedures and methods for inspecting and identifying leaking equipment, and for performing and documenting repairs
A list of personnel responsible for performing LDAR program activities and a description of their roles and responsibilities, including the person(s) responsible for implementing improvements to the LDAR program
Policies and systems for delivering training to responsible personnel, as well as methods for tracking and evaluating training completion
Procedures for periodic audit of the LDAR program
Procedures (e.g., a Management of Change system) to ensure that new equipment and components in each process unit are evaluated for applicability of LDAR requirements, and that affected components are integrated into the LDAR program
A system for evaluating new and replacement equipment to identify and eliminate components that are prone to leaks
LDAR Training Management
Leak detection, equipment repairs and other LDAR activities require a high degree of skill and training to be performed safely and effectively. For example, LDAR requirements mandate the use of EPA Method 21 for detecting leaks of VOCs. Method 21 is a highly technical standard which specifies the equipment types that must be monitored, leak detection thresholds, specifications and calibration limits for approved monitoring devices, and detailed physical testing procedures. EPA cites improper application of Method 21 among the most common LDAR compliance issues, so it is vital that monitoring technicians are familiar with its requirements in order to obtain accurate and reliable test results.
Employers should provide LDAR monitoring technicians and other program personnel with intensive training and periodic re-training, and have a system in place for scheduling and tracking training completion. Implementing an electronic training management system can help you stay ahead of these continuously shifting demands by dramatically reducing the administrative burden of scheduling, documenting, and evaluating employee training. Such systems allow individual employee training records to be created and modified in real-time to reflect current training status, while providing centralized access to those records to quickly verify and evaluate training completion. Electronic training management systems can also give you the ability to automatically notify employees and supervisors via email and system alerts when training requirements are approaching or past due.
The Importance of Recordkeeping
According to recent EPA studies, the average affected facility has more than 20,000 LDAR-regulated components. Facilities like ExxonMobil’s Baytown Refinery, whose sprawling network of pipelines and process equipment covers approximately 5 square miles, may easily have in excess 100,000 components — each of which must be inspected on a monthly basis.
Leaking components must be identified and repairs made within the time limit specified by the applicable NSPS requirements, with a first attempt at repair generally required within 5 days, and final repair within 15 days. If repairs cannot be made within the specified time, or inspection and repair cannot be conducted due to technical infeasibility or unsafe conditions, those circumstances must also be clearly documented, and closely monitored to ensure follow up. Affected facilities are required to maintain detailed records of all LDAR program activities, including component inspections, monitoring data, repairs and replacements, dates, times and assigned personnel for a period of 5 years.
Every four years, affected facilities must perform both facility-led and third-party audits of the LDAR program, with audits alternating at two year intervals. The purpose of these audits is to ensure that LDAR programs are achieving stated emissions reduction goals, and that any program deficiencies are identified and addressed. Audits should include observations of LDAR monitoring technicians to verify adherence to Method 21 requirements, review of data collection, entry and QA/QC processes for accuracy and completeness, review of LDAR component lists to ensure that all regulated components are being inspected, and evaluation of corrective action management processes to ensure repairs are being made within the required time-frame. It goes without saying that, in order to facilitate an effective audit from which valuable insights can be gained, auditors must have accurate and complete records of all LDAR program activities.
EPA has expressed that organized and readily available records are a primary indication of an effective and compliant LDAR program, and are likely the first thing enforcement officials will refer to when evaluating LDAR compliance at a facility. To assist with compliance, EPA has developed several LDAR program best practices, including the use of electronic recordkeeping software to collect and store all required data.
Even with the use of electronic recordkeeping systems, many facilities still struggle with LDAR compliance due to the fact that they are using multiple separate systems to help them perform and monitor individual program activities.
For example, some facilities may use one system to schedule and perform monthly component inspections, another to record and analyze the monitoring data, and yet another to manage the resulting repairs and other corrective actions. This is an unnecessarily complex and inefficient approach.
Effective and well-developed LDAR programs take advantage of EHS software solutions that help consolidate multiple LDAR program capabilities so that audits and inspections, monitoring data, corrective actions, management of change processes, and even training can all be quickly and intuitively managed using a single software system.
Though individual NSPS vary with regard to the types of facilities and emissions they regulate, each applies virtually identical LDAR requirements. This means that having an effective and well-developed LDAR program in place can dramatically simplify compliance with the multiple NSPS requirements that may apply to your facility.
By Greg Duncan
Greg Duncan is an EHS & Sustainability Expert at VelocityEHS, an award-winning cloud software company that delivers a comprehensive suite of EHS products that help companies better manage incident management, corrective actions, compliance issues and reporting, and safety meetings management. To learn more about VelocityEHS and how it can help you reach your EHS goals faster through faster implementations and easier to use products, visit www.EHS.com Or call 888-362-2007.